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TMI Blog2023 (4) TMI 373X X X X Extracts X X X X X X X X Extracts X X X X ..... arge in the show-cause notice issued u/s 274 r.w.s. 271(1)(c) of the Income Tax Act. AO is required to specify the charge on which an assessee has to give explanation, namely whether penalty is to be imposed upon the assessee for concealment of income or for furnishing of inaccurate particulars. In the judgments cited before us, this question has been answered in favour of the assessee, i.e. in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 passed for A.Y. 2013-14. 2. The solitary grievance of the assessee is that ld. CIT(Appeals) has erred in confirming the penalty of Rs.77,65,050/- imposed by the ld. Assessing Officer under section 271(1)(c) of the Income Tax Act. On the strength of the following decisions (whose copies have been placed on record):- (i) Pr. CIT-19, Kolkatavs. Dr. Murari M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9.01.2023 3. Ld. Counsel for the assessee has contended that in the show-cause notice issued under section 274 read with section 271(1)(c) , the ld. Assessing Officer has not specified the charges against the assessee for visiting with penalty under section 271(1)(c) of the Income Tax Act. He took us through copy of the show-cause notice available on page no. 1 of the paper book ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... required to specify the charge on which an assessee has to give explanation, namely whether penalty is to be imposed upon the assessee for concealment of income or for furnishing of inaccurate particulars. In the judgments cited before us, this question has been answered in favour of the assessee, i.e. in case, the charge is not specified in the show-cause notice, then penalty would not be imposa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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